August 7, 2024

Register Now for the Fall 2024 EGHSS Meeting and Save the Date for 2025!

ILTA’s Fall Environment, Government, Health and Safety, and Security (EGHSS) meeting is set for October 1-2 in Chicago, IL! See the full agenda here. 

ILTA is committed to advocating strongly for the terminal industry in Washington, and our committees play a crucial role in keeping us aligned with the industry's top priorities. As deeply engaged tank and terminal professionals, your active involvement is vital to our success, and we sincerely appreciate your contributions. We eagerly anticipate your presence as we understand the importance of having terminal industry professionals responsible for environmental, health, safety, and security compliance at all levels. Whether you're an experienced expert or a budding professional, we welcome your participation in our committees.  

The event will be held at The Drake Hotel. You can register and book your room here! 

Save the Date for our EGHSS 2025 Meetings:

March 11-12 in Louisville, KY and September 30 - October 1 in Denver, CO

Call for ILTA 2025 Proposals is Now Open!

Share your knowledge and experiences at the ILTA 2025 Conference & Trade Show, June 9 - 11! We encourage all submissions related to terminals, especially those in the Environment, Health and Safety, Security, Leadership, Operations and Engineering, Human Resources, and Emergency Response areas. 

There are a limited number of sessions, so please submit your proposal by October 7, 2024. 

 Click here to learn more and submit your proposal.

The 2024 ILTA Compensation & Benefits Survey is Open!

This annual survey provides terminal companies the opportunity to compare their compensation and benefits with industry averages. The survey requests compensation figures for a variety of different positions in the terminal industry, as well as information on benefits, including healthcare coverage, retirement plans, wellness programs, and different forms of leave.

All ILTA terminal member companies are encouraged to participate in this survey program. As a participant, you will receive a complimentary digital copy of the Industry Report and a confidential, individualized Company Compensation Report with your compensation and benefits statistics reported alongside the appropriate industry comparatives.

Please click here to learn more and begin the survey.

ILTA’s Safety Moments Library

ILTA is dedicated to promoting safety moments in the liquid terminals industry. At ILTA, safety is at the forefront of everything we do, and we are committed to providing valuable resources to enhance safety practices within our industry.

On this webpage, you will find a wealth of information, resources, and support to help you effectively incorporate safety moments into your daily operations. Whether you are a seasoned industry veteran or new to the liquid terminals sector, we invite you to explore our content and discover valuable insights that can make a significant difference in workplace safety.

Log on to ILTA Connect, the New Terminals Industry Community Platform!  

ILTA recently launched ILTA Connect, a new community platform for ILTA terminal members! ILTA Connect is meant for members to share relevant information and news about what’s going on in our industry, ask questions, and foster discussion. In this space, you will be able to join different communities based on committees and working groups.     

This platform is your new “go-to” site to explore environment, health, safety, security, and operations topics and receive rapid feedback from your peers. ILTA Connect serves as a place to continue your conversations from ILTA meetings and events and it is your gateway to members-only resources like safety moments and sustainability reporting shared by other ILTA members.  

Log on to ILTA Connect today using your ILTA member account or create an account if you don’t have one. For further questions or to resolve any issues with your account, please email membership@ilta.org.  

ILTA 2025 Trade Show Rebooking 

Rebooking for the 2025 trade show is underway! If you have not filled out your application to exhibit, please contact Justin Olson at jolson@thewymancompany.com.

ILTA Submits Petitions on EPA Gasoline Distribution Rules

As part of the ongoing conversation around EPA’s final gasoline distribution rule, ILTA submitted two petitions challenging the rule and its implementation: a petition for reconsideration and a petition for judicial review. These petitions essentially act as another set of industry comments on the rule but the latter acts as a legal backstop to challenge EPA’s decision in a federal court if the agency were to ignore the issues raised.

From undue regulatory burden to unreasonable cost and construction, ILTA’s comments were expansive. ILTA would like to thank both Trinity Consultants' Harold Laurence for leading in this effort and the professionals in ILTA’s Air Permitting Working Group who dedicated dozens of hours over the last few months to inform the industry’s response. You can read ILTA’s petitions on our website.

Regarding next steps, ILTA plans to meet with EPA on the petitions sometime in August and ahead of EPA’s formal response. EPA will need to respond by the end of 2024 and ILTA will keep its membership apprised as more developments emerge. 

ILTA to Join Conn Maciel Carey on Two OSHA Rulemaking Comments: Emergency Response and Heat Illness Rulemakings

OSHA recently announced a Notice of Proposed Rule Making (NPRM) on Heat Injury and Illness Prevention which would require all employers conducting business in general industry, construction, maritime, and agriculture sectors to develop and implement Heat Injury and Illness Prevention Plans (HIIPP). ILTA has joined an industry coalition headed by Conn Maciel Carey LLP, a law firm that specializes in labor and employment matters, to help provide comments as the rule-making process continues.

This NPRM will have a real impact on our industry, and we must receive comments and insights from our ILTA members. If you have any questions on the NPRM or how you can get involved, please reach out to James Privette, Government Affairs and Communications Manager at jprivette@ilta.org.

ILTA Holds Summer 2024 Board Meeting in Traverse City, MI

ILTA’s Board of Directors held its summer 2024 meeting in Traverse City, MI over July 25-26. The board participated in a strategic planning exercise aimed at charting the association’s direction and growth over the next three to five years. Advocacy was a key focus, expanding on the association’s voice in Washington, DC in both the regulatory and legislative spaces. Likewise, beyond expanding our events and membership, ILTA has also committed to exploring ways to gain accreditation for Continuing Education Units (CEU) at its various events throughout the year.

ILTA Partnering with Nossaman LLP to Develop Comments on CIRCIA Rule 

In response to DHS CISA’s April 4, 2024 proposed Cyber Incident Reporting for Critical Infrastructure Act (CIRCIA) rule, ILTA has partnered with Nossaman LLP to develop formal comments. On June 11, Nossaman held a meeting with ILTA’s Security Subcommittee to discuss the rule and initial member concerns. A draft set of comments was distributed to members for feedback on July 1 ahead of the July 3 deadline to submit. You can read the submitted comments on our website here.  

DOD Preparing to Ask Congress to Extend Deadline for Ending AFFF Use

The Department of Defense (DOD) is preparing to ask Congress for a one-year extension of its October deadline to end its use of PFAS-containing firefighting foam (AFFF). In briefing slides from June, DOD indicated that it plans to submit a written certification to the congressional defense committees by August 2, requesting the extension to ensure a methodical and safe transition towards fluorine-free foam (F3). While the fiscal year 2020 National Defense Authorization Act (NDAA) requires DOD to stop using AFFF by October 1, 2024, the law allows the Secretary of Defense to invoke two one-year extensions by detailing to Congress both the progress made in finding a PFAS-free replacement and the challenges faced in the transition. Following this extension request, DOD is also likely to request the second one-year extension next year, moving the final deadline to October 1, 2026.

The challenges DOD faces in its transition from AFFF to F3 echo similar obstacles faced by the liquid terminal industry. DOD has stated numerous reasons for its extension request, including the capability limitations of F3, steep funding requirements, difficulty maintaining safety standards, and infrastructure challenges. While DOD is evaluating alternative technologies and methods other than firefighting foam to phase out AFFF, DOD acknowledges that there is no single technology suitable for every situation.

Low Carbon Fuels Markets for Renewable Diesel and Sustainable Aviation Fuel are Evolving

On July 17, ILTA hosted its monthly Energy Transition webinar. The July session featured Bill Tyndall, Partner, and Jo Thapa, Associate, from AJW, Inc. to discuss the anticipated growth and shifting demands of low-carbon fuels markets. Bill and Jo provided an overview of the current and projected growth of renewable diesel, sustainable aviation fuel (SAF), and other biofuels, highlighting driving policies such as the IRA tax credits, California’s Low Carbon Fuel Standard (LCFS), and the federal Renewable Fuel Standard (RFS). Additionally, they updated attendees on the latest status of emerging state clean fuel standard programs.

Bill and Jo discussed how incentives are rapidly expanding the market for renewable diesel, noting that these incentives are declining in value due to overproduction and changing credit value formulas. While the LCFS has made the California market the key destination for renewable diesel, Bill and Jo noted how the more recently established clean fuel programs in Oregon and Washington are expected to create new renewable diesel markets. Additionally, they pointed out that the new domestic production requirement for renewable diesel under the 45Z tax credit may cause market importers to shift to feedstocks rather than the finished product. Last, they acknowledged that the domestic market for SAF is still nascent, but states such as California are considering expanding the LCFS program to include SAF for intrastate flights starting 2028. These evolving policies and market conditions for low-carbon fuels present the terminal industry with new opportunities to meet changing biofuel demands.

ILTA Think Tank Blog: The Importance of Mitigating CERCLA Liability for Bulk Liquid Terminals Over PFAS Firefighting Foam Use

ILTA’s Think Tank Blog is returning! Check out our newest iteration, which was published in BIC Storage Magazine, and read the full piece on our website.

From clothing to cookware, flame retardant per- and polyfluoroalkyl (PFAS) chemicals have become ubiquitous in our daily lives. For bulk liquid terminals specifically, PFAS compounds are used in aqueous film-forming foams (AFFF) or film-forming fluoroprotein foams (FFFP) foams because of their exceptional ability to create a stable and effective firefighting foam, particularly for extinguishing liquid fuel fires, such as those involving gasoline, jet fuel, or oil.

Due to their near-indestructibility and persistence in local environments where they are used, however, states and the federal government are increasingly focusing on the environmental and public health consequences of the use of PFAS-based products. In March 2024, the Senate Environment & Public Works Committee held a hearing on, “Examining PFAS as a Hazardous Substance.” One month later in April, the Environmental Protection Agency (EPA) issued the first-ever national, legally enforceable drinking water standard to protect communities from exposure to harmful PFAS, while also finalizing a rule to designate two widely used PFAS – PFOA and PFOS – as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA), also known as Superfund.